I’m back with Jason Grant of Jason Grant Consulting to continue our discussion about LEED’s new Timber Traceability pilot credit. Last week we looked at the principal concept behind this, the declare, map and test approach. This week, let’s look at how this came about.
Tell me, Jason, how long as this credit been in development? What’s the history behind it? What were some of the challenges in creating it?
Jason: The credit took over two years to develop and is the result of a collaboration between USGBC and environmental NGOs. There were many challenges in creating it. The single largest one was digging through a mountain of complexity to arrive at an approach that we think is both workable given the realities of the way supply chains work in delivering wood products to building projects, and effective in addressing the real barriers to avoiding illegal wood.
What organizations were involved? Was the program vetted or reviewed by builders and architects as well?
Jason: The main environmental NGOs involved were World Wildlife Fund and Environmental Investigation Agency, although forest legality experts in other organizations were also consulted. The approach was reviewed by several architects who are expert LEED practitioners, and also with individuals with direct experience in supplying wood into building construction. Also, USGBC’s top LEED technical person was heavily involved.
How does this work with other regulations and programs out there? What’s the relationship with Lacey, FSC & PEFC, the EUTR, CITES, etc.?
Jason: There are three distinct issues within your question, so let me break it down. First, the easy one—if the species is listed under CITES, of course all necessary permits and documents should be provided and the goal is to scientifically verify the accuracy of the sourcing.
For FSC & PEFC, there are two points to note. First, for any material sourced from high risk countries, the requirement is that they be FSC or PEFC certified. Before you ask, I know this begs the question: how do people know if a country is high risk? We have taken a straightforward approach that relies on Transparency International’s Corruption Perception Index – if a country has a score of 50 or less on the Index, then it is considered high risk for the purposes of this credit. Second, the fact that a product is certified does mitigate risk but it can’t be seen as proof of legality, as there have been cases where unscrupulous companies have been caught selling illegal wood as certified—so we still expect to test FSC or PEFC material and attempt to confirm the declared species and/or origin.
Finally, as discussed last week, this is in part created in response to forest legality regulations such as Lacey and EUTR and the need for approaches that have more teeth than document-based risk mitigation or occasional pre-scheduled audits, both of which are vulnerable to gaming. The idea behind LEED is that it reaches well beyond regulatory minimums or status quo practices, be it for energy efficiency, more recycled content, or better indoor air quality. So it makes sense for LEED raise the bar for due diligence under Lacey or other regulations to a new level.
You talked last week about labs and testing systems, however for the pilot, I see that an ENGO, the Environmental Investigation Agency (EIA), is responsible for receiving maps and samples, performing the tests and evaluating the results. Will they be using the information gathered for other purposes, either specific to the product/manufacturer or in aggregate?
Jason: EIA has stepped in to manage testing on an interim basis while efforts to arrange a permanent institutional infrastructure to implement the declare, map and test approach continue. EIA has a wood ID expert on staff and will use labs that are the current leaders in the field. The information gathered will not be used for any purpose other than determining whether or not credit requirements have been met.
This is a pilot credit. Is it available in LEED programs in all countries, or just the US? And is it available in all versions and types of LEED programs, such as residential and commercial and both new construction and remodeling, etc.?
Jason: It’s available in LEEDv4 projects internationally that use the New Construction rating system, which applies mainly to commercial and institutional projects. I believe this is the most widely used rating system now.
Have some companies already gone through this? How has it worked in practice so far?
Jason: No one has gone through it yet because the pilot credit is brand new, so we have yet to see how well it works. As I noted previously, the whole point of a pilot credit is to stress test a new approach in real world situations so as to identify and work out the kinks. People can provide ideas for improvement on the credit using the LEEDuser forum that’s been set up for it.
And what is the process by which this becomes a regular credit category, not just a pilot?
Jason: There is no set process. USGBC decides this on a case-by-case basis.
Thank you, Jason. Next week, let’s discuss how it’s going to actually work in practice.
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.